Lawsuit for Customer Fall from loose Booth at Restaurant - Plaintiff's Response to Defendant's Request to Produce

IN THE CIRCUIT COURT OF THE 11^TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY,  FLORIDA

CASE NUMBER: 2007

CLIENT,

Plaintiff,

vs.

DENNY'SRESTAURANTS, LLC,

Defendant.

___________________________________________/

DRAFT OF PLANTIFF'S RESPONSE TO REQUEST FOR PRODUCTION

Plaintiff, CLIENT, hereby responds to the Defendant, DENNY'SRESTAURANTS, LLC, INC.'S Request For Production dated December __ 2007 by corresponding number as follows:

•1. Attached are Plaintiff's medical bills in our possession.

•2. Attached are Plaintiff's medical records in our possession.

•3. Attached are Plaintiff's MRI reports or other diagnostic testing in our possession.

•4. Objection, work product, however if defendant agrees to produce their photographs and

video including surveillance, plaintiff will produce the photographs and/or video they have of the accident scene, the subject premises and the plaintiff.

•5. Objection overbroad, to providing tax returns for the past five years. As to tax returns for the

past three years, none in our possession, but will produce upon receipt.

•6. None

WE HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this

JUSTIN ZIEGLER, ESQ.

Co-counsel for the plaintiff

9100 S. Dadeland Boulevard

Suite 908

Miami, Fl. 33156

T: 305-403-0966

F: 786-235-0793

Florida Bar #: 662305

______________________________

By: JUSTIN ZIEGLER